HMO Compliance Checklist 2026: Gas Safety, EICR, EPC & More

HMO compliance in 2026: what landlords need to know

A House in Multiple Occupation (HMO) is defined as a property occupied by 3 or more people forming 2 or more separate households, who share facilities such as a bathroom or kitchen. HMOs of 5 or more people forming 2 or more households require a mandatory licence from the local council.

Running an HMO in 2026 carries a significantly higher compliance burden than a standard single-let property. This checklist covers everything you need to have in place.

Mandatory HMO licence

If your HMO has 5 or more occupants forming 2 or more households, you need a mandatory HMO licence from your local authority. Some councils have adopted Additional Licensing schemes that extend licensing requirements to smaller HMOs - check with your local council.

Key requirements:

• Apply before occupation, not after
• Licences typically last 5 years
• You must declare the maximum number of occupants and the layout
• The property must meet the council's room size and amenity standards

Record what you need:

• Licence number
• Issue date and expiry date
• Conditions attached to the licence

Gas Safety (Annual)

All gas appliances, pipework, and flues must be inspected annually by a Gas Safe registered engineer. A Landlord Gas Safety Record (CP12) must be issued after each inspection.

Timeline obligations:

• Inspect within 12 months of the previous inspection
• Serve a copy on existing tenants within 28 days of the inspection
• Serve a copy on new tenants before they move in
• Keep records for 2 years

What to check on the certificate:

• Date of inspection (must be within the last 12 months)
• Address of the property
• Engineer's Gas Safe registration number
• List of appliances checked and results
• Expiry date (12 months from inspection date)

EICR - Electrical Installation Condition Report (Every 5 years)

An EICR must be carried out by a qualified electrician every 5 years, or at the start of a new tenancy if the previous report is more than 5 years old.

Timeline obligations:

• Carry out before the start of any new tenancy if EICR is more than 5 years old
• Serve a copy on tenants within 28 days of the report
• Carry out any required remedial work within 28 days of the report (or the shorter period specified)
• Obtain written confirmation from the electrician that remedial work is complete

Acceptable outcomes:

• Satisfactory - no action required
• Unsatisfactory - remedial work must be completed before tenants occupy or within 28 days

EPC - Energy Performance Certificate (Every 10 years, minimum E rating)

An EPC must be obtained before marketing or letting a property. The property must have a minimum rating of E. Properties rated F or G cannot legally be let under the Minimum Energy Efficiency Standards (MEES).

Important notes for HMOs:

• Each self-contained unit within an HMO may need its own EPC
• Non-self-contained HMOs (shared kitchen/bathroom) typically need one EPC for the whole property
• The EPC must be made available to prospective tenants

Tighter MEES standards are expected in coming years, with a C rating potentially required by 2028 - although timelines for private sector mandation remain under consultation.

Fire safety (HMO-specific requirements)

HMOs have additional fire safety obligations under the Housing Act 2004 and the Regulatory Reform (Fire Safety) Order 2005:

• Fire risk assessment - required for all HMOs with 3 or more storeys or 5 or more occupants
• Interlinked smoke alarms - required in every room and hallway
• Carbon monoxide detectors - required in any room with a solid fuel appliance or gas appliance
• Fire doors - required between high-risk areas (kitchen) and escape routes
• Emergency lighting - required in some larger HMOs
• Fire blankets and extinguishers - required in kitchens

The specific requirements depend on the size, layout, and storey count of the HMO. Your local council's licensing conditions will specify the standard required.

HHSRS - Housing Health and Safety Rating System

Local councils use the HHSRS to assess properties for hazards across 29 categories, including damp and mould, excess cold, fire, falls, and carbon monoxide. Category 1 hazards (serious risk to health) can trigger enforcement action.

Landlord obligations:

• You do not need to proactively carry out an HHSRS assessment yourself
• However, you must address hazards when they are identified (by a council inspector, a tenant complaint, or your own survey)
• Retaliatory eviction in response to a disrepair complaint is a statutory defence for tenants

STEMHQ's HHSRS Hazard Tracker lets you log and track all 29 hazard categories per property with severity, inspection dates, and resolution status.

Deposit protection

For any HMO with individual room lets, each tenancy agreement typically involves a separate deposit. Each deposit must be:

• Protected in an approved scheme (DPS, TDS, or MyDeposits) within 30 days of receipt
• Capped at 5 weeks' rent
• Accompanied by Prescribed Information served on the tenant within 30 days

STEMHQ's compliance heatmap

STEMHQ tracks Gas Safety, EICR, and EPC expiry dates across every property in your portfolio and displays them as a colour-coded heatmap on the Portfolio page. Certificates expiring within 60 days show amber; expired certificates show red. You receive notification alerts so you are never caught off guard.